Material safety data sheets (MSDS) are essential elements of hazmat management. The U.S. Occupational Safety and Health Administration (OSHA) requires employers to provide information to their employees about the hazardous chemicals to which they are exposed under its hazard communication standard.
Departments must have MSDS organized and accessible, meaning that sheets are arranged alphabetically in loose-leaf binders or on computer, and are updated every time a new product or formula arrives. The biggest challenge for maintenance and engineering managers is maintaining up-to-date MSDS on hundreds of chemicals found throughout their facilities.
“Keeping MSDS up to date and knowing you’ve got all the material out there covered is the hardest part,” says Jerry Ivey, systems facility engineer for Willis-Knighton Health Systems in Shreveport, La. For example, hazardous chemicals can enter a facility without safety officers’ or managers’ knowledge. Also, manufacturers might update or change an MSDS and not send a revised version. Or newly ordered or updated sheets might not make it to the right department.
Unless housekeeping departments have a well-maintained and organized system, it is difficult for managers to know about missing or outdated MSDS.
The best way to ensure all MSDS are on file is to do a complete inventory of all chemicals and hazardous materials. Some organizations have a safety officer or a purchasing department who is in charge of inventory, while others might have individual maintenance departments do their own inventory. To stay on top of changing inventories and MSDS, this person should perform inventory annually, cross-checking the list of existing materials with MSDS.
“The list of materials should be checked against existing MSDS to determine what sheets are missing,” says Jeffrey Camplin, president of Camplin Environmental Services in Rosemont, Ill. Some departments don’t know what they have, in terms of materials that are no longer used, outdated or expired.
“Go through the facility, and get an accurate assessment of what requires MSDS,” says Gary Rubell, a consultant with Compliance Management Corp., a division of Safety Compliance Institute Inc. in Chatsworth, Calif. “Almost everything in a work environment is considered hazardous.” A period inventory check ensures that departments get an up-to-date file of MSDS, and it shows whether sheets are missing.
“We ask the various departments on campus to evaluate their products,” says Mike McCauslin, assistant director of risk management and safety at the University of Notre Dame. “Each year, we tell them to request an updated MSDS from their suppliers.”
The building services department, for example, gives a copy of an updated sheet to McCauslin’s department, which manages 25,000-30,000 MSDS. For some organizations, having a specific department responsible for maintaining a master MSDS list makes for a more streamlined process of updating and filing sheets.
Even with regular inventory and a good MSDS management system, sometimes departments have trouble receiving an MSDS.
“Just getting MSDS is difficult,” Ivey says. “Some ship it, and it gets thrown out by the person who received it. Some (manufacturers) send it by mail after the fact.”
Facilities should have a system for routing MSDS to the right departments.
“Purchasing departments pass the sheets off (to other departments) when they receive MSDS with shipments,” Rubell says. “Make sure purchasing departments know how important MSDS are.”
At the University of Notre Dame, the department of risk management and safety acts as an MSDS clearinghouse. Among other things, the department determines to which academic division or operations department a particular sheet goes.
“We have contacts in all departments,” McCauslin says. “Most MSDS go to the director of the department that gets the material. Many times, they (MSDS) come directly to us.” Some organizations take a different approach by having purchasing departments handle MSDS filing and data entry in a master list for all facilities.
“The person in charge of ordering products logs new MSDS in a central file on computer,” says Nathan Norman, director of building services at the University of Michigan.
Even though OSHA requires manufacturers to send MSDS with product orders and when they revise MSDS, sheets might or might not make it to a facility.
“You never know if a company changes its MSDS because they don’t send it to you, or you don’t get it,” Ivey says. Some manufacturers make MSDS available on their Web sites so managers or supervisors with Internet access quickly can get the updated version. Otherwise, department managers or supervisors call the manufacturer and request one. Having to make phone calls, do inventories, search Web sites and make copies, managing MSDS can be very labor-intensive.
“Sometimes, you have to get very busy people to make sure everything is updated,” says Jennifer Combs, environmental manager for the department of facilities at the Massachusetts Institute of Technology. “Sometimes, you have to ask a busy supervisor to review MSDS, and you wonder, did they really look at it?”
With regular review of MSDS and filing systems, housekeeping managers can keep up their files current and accurate. Each time a department purchases a new product, the manager should get in the habit of specifically requesting an MSDS to be sure the department has the most recent version.
As daunting as this management process can be, it is essential for employee safety, as well as regulatory compliance. Facilities run the risk of an OSHA citation if all MSDS are not on site or if employees do not know where MSDS are located.
